ENVIRONMENTAL

MONITORING

PLAN

for imidacloprid

ASIAN LONGHORNED BEETLE COOPERATIVE ERADICATION PROGRAM

2015

 

United States 

Department of

Agriculture 

Animal and Plant 

Health Inspection

Service

Plant Protection

and Quarantine

Regulations, Permits 

and Manuals 

Compliance and 

Environmental 

Coordination

 February 2015
General

The United States Department of Agriculture (USDA) - Animal and Plant Health Inspection 

Service (APHIS) Directive 5640.1 (4/19/02) commits the Agency to a policy of fulfilling the 

mandates of the National Environmental Policy Act; the Endangered Species Act; the Federal 

Insecticide, Fungicide, and Rodenticide Act; and other statutes that require monitoring the 

potential effects of Federal programs on the environment. The monitoring described in this 

Environmental Monitoring Plan (EMP) supports these commitments for the Asian Longhorned 

Beetle (ALB) Cooperative Eradication Program.

Environmental sampling for residues of imidacloprid is used to validate the assumptions of the 

Environmental Assessments created for the program and to address specific concerns raised by 

the public. Imidacloprid is a systemic insecticide used as a treatment of ALB host trees at risk 

for infestation. ALB host trees may be treated via ground or trunk injection based on the size of 

the tree, local hydrology, and other factors. APHIS’ risk analysis identified several pathways 

that could cause pesticide residues in the environment. The analysis evaluated the potential for

harmful effects on several groups of organisms based on their possible pesticide exposures from 

pollen and leaves from treated trees, soil and groundwater at injection sites, and soil or surface 

water where fallen leaves accumulate. Monitoring will be conducted to determine if ALB 

Program systemic treatments of host trees result in the movement of imidacloprid beyond the 

immediate treatment area. 

Samples collected as part of this plan will be reported to the ALB Program management in an 

annual report. If any residue samples seem unusually high, ALB Program management will be 

contacted immediately to determine what, if any, action may be needed to adjust Program 

operating procedures. This monitoring plan is a working document and will be updated as 

needed based on new information provided to the PPQ Compliance and Environmental 

Coordination (CEC) staff. It is designed to be a reference document for staff that will collect and 

document monitoring samples during the ALB eradication program. 

Human and Environmental Health

Objectives

Monitoring for potential exposure is designed to: 

1. demonstrate the effectiveness of ALB operational procedures in excluding or minimizing

exposure of the public and the environment to Program-applied imidacloprid;

2. collect data which can be used to evaluate whether the assumptions used in the 

Environmental Assessments are valid estimates of potential exposure of the public and 

the environment to Program-applied imidacloprid; and

3. investigate any Program-related complaints or reports of adverse effects on public health, 

worker safety, environmental quality, or non-target species.

Methods

This document is a reference for ALB program staff. If additional or new types of monitoring 

are necessary, please contact the CEC staff (Kai Caraher) at 301-851-2345 or by email at 

kai.caraher@aphis.usda.gov for guidance. APHIS environmental monitoring is flexible and 

2015 Environmental Monitoring Plan 1
easily altered, but discussions will be needed to determine the best course of action given the 

analytical tools available.

Sampling Locations and Schedule

The ALB program should monitor the same sample locations selected in previous years if the 

treatment areas have not changed. When program managers plan to apply imidacloprid, 

collection of pre-treatment samples allows APHIS to determine if the pesticide is already present 

in the environment. Collect post-treatment samples at these stations approximately one week 

after the treatments conclude and then approximately one, three, and six months later if possible. 

Where the ALB program initiates treatments at new areas, managers should consider additional 

sample locations and consult with the CEC staff.

Sensitive Site Inventory

The ALB program will identify sensitive sites prior to the initiation of chemical treatments. 

Sensitive sites are areas where the public may be exposed directly to chemicals and areas where 

there are specific concerns about potential impacts due to program activities. The program will 

identify any surface waters used as a source of drinking water in or adjacent to the proposed 

treatment area. Additional sensitive sites may include, but are not limited to, the location of 

apiaries, schools and playgrounds, and groundwater supply wells.

Program managers must provide descriptions and locations of sensitive sites near treatment areas 

to the CEC staff. It is preferred that these lists be submitted in an electronic form, but they may 

also be submitted as a printed hard copy. Note the name and location of the water, the type of 

water (river, lake, etc.), and the distance and direction from the nearest treatment area. Prior to 

the start of chemical treatments, provide the list of sensitive sites to the CEC staff at the 

following address:

Kai Caraher, USDA-APHIS-PPQ,

4700 River Road

Unit 150, Room 4C-01.33, 

Riverdale, MD 20737

or via email to kai.caraher@aphis.usda.gov

Minimum Required Sample Sizes

Sample collection procedures are described below, but for easy reference, the following table 

provides the minimum sample sizes required to analyze a single sample type for imidacloprid:

Sample Type Minimum Sample Amount

Leaves, twigs, bark 30 grams

Soil, sediment 100 grams

Water 1000 ml

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It may be possible to analyze smaller samples, but at best, they will be less precise. If the 

minimum sample size is not available, collect as much as possible from the sample location. The 

table above shows the types of samples that the lab can currently analyze. If other types of 

samples are collected, their analysis is not guaranteed and it could take several months for the lab 

to develop a satisfactory analytical method. Do not take samples beyond those in the table, as 

the lab may not have techniques to analyze such samples.

Surface Water Samples

Program personnel may collect surface water samples near the shore of ponds, rivers, or 

reservoirs, with priority given to any identified as a source of drinking water. Approximately 

one week prior to the initiation of the spring treatments field personnel should collect pretreatment surface water samples. Collect post-treatment samples at these stations approximately 

one week after the treatments conclude and then approximately one, three, and six months later if 

possible. Be careful to ensure the water samples are free of turbidity and sediment. One liter of 

water will be collected for analysis from each sample station. Following collection, samples will 

be kept on ice, in the dark, and remain chilled until they can be frozen for shipment. For more 

detailed information on sampling procedures, refer to SOP EM-03 Collection of Water Samples.

This and other referenced SOPs are available at:

http://www.aphis.usda.gov/wps/portal/aphis/ourfocus/planthealth?1dmy&urile=wcm%3apath%3

a%2Faphis_content_library%2Fsa_our_focus%2Fsa_plant_health%2Fsa_domestic_pests_and_di

seases%2Fsa_emt%2Fct_support_docs. 

Leaf Litter Samples

Whenever possible, the program should collect leaf litter samples where surface water samples 

are collected. Collect leaf litter around treated trees and near or up gradient from the surface 

water sample. If no leaf litter is available, please note that on the 2060 Environmental 

Monitoring Form for the water sample. If no leaf litter is available, do not collect leaves that are 

on trees, and do not collect conifer needles. For more detailed information on sampling 

procedures, refer to SOP EM-07 Collection of Vegetation Samples.

Soil Samples

Whenever possible, collect soil samples each time surface water samples are collected. Collect 

soil from three to six inches from the surface around treated trees or beneath windblown piles of 

leaves from treated trees. For more detailed information on sampling procedures, refer to SOP 

EM-06 Collection of Soil Samples.

Monitoring for Incidents or Complaints

Priority sampling will be conducted to investigate incidents of unknown origin involving nontarget species or other unintended environmental or human health impacts possibly associated 

with ALB program applied imidacloprid. Information about priority sampling can be found in 

SOP EM-09, Priority (Emergency) Sampling. Collect priority samples as soon as possible after 

the complaint, request, or problem is reported. Contact the CEC staff to collaborate on a 

sampling plan, sampling methods, and types of samples to collect in order to optimize the 

investigation. If the incident occurs on a weekend, commence the investigation and sampling 

without delay, and contact the CEC staff as soon as possible. 

2015 Environmental Monitoring Plan
Dr. Robert Baca, 301-851-2292, robert.m.baca@aphis.usda.gov, or

Kai Caraher, 301-851-2345 (office), 202-288-3086 (mobile), kai.caraher@aphis.usda.gov

Send all incident or complaint samples to the APHIS-PPQ laboratory in Miami, Florida instead 

of the AMS-NSL laboratory in Gastonia, North Carolina. Follow the directions in SOP EM-09

for details.

Proper documentation of the incident, investigation, and samples is extremely important. When 

responding to priority incidents, send to the CEC staff all GPS maps showing the site, location 

where samples were collected, the nearest treatment area, and a narrative of the treatment 

history. Be sure to completely fill out all information on the APHIS 2060 forms with each 

sample. Be sure to provide an incident or complaint report to the CEC staff, along with any 

other information that you feel will be helpful in resolving the incident (i.e. photos, observations 

at the site, etc.).

Sample Processing

Shipment of Samples

All routine monitoring samples must be sent to the Agricultural Marketing Service, National 

Science Laboratory (AMS-NSL) in Gastonia, North Carolina at: 

Attention: Roger Simonds

AMS National Science Laboratory (NSL)

801 Summit Crossing Place Suite B

Gastonia, NC 28054 

Phone: 704-867-3873

The methods used by the AMS-NSL will require strict adherence to sample condition protocols. 

Therefore field samples that do not meet the recognized standards for collection and preservation 

will be rejected prior to analysis. 

All priority (i.e. incident) samples must be sent to the PPQ - Center for Plant Health Science and 

Technology (CPHST) Laboratory in Miami, Florida at:

Attn: Lisa Mosser/Bill Guyton 

USDA-APHIS PPQ S&T CPHST Miami Laboratory 

13601 Old Cutler Rd, Bldg. 89 

Miami, FL 33158

Phone: 305-278-4902 or -4885

Ship all samples by using some form of overnight delivery. See SOP EM-17, Packaging and 

Shipping of Samples for details. This applies to all samples, whether they are priority or routine. 

Do not ship samples using the U.S. Postal Service Priority Mail or standard ground service with 

other carriers. Overnight delivery ensures the sample will remain frozen or at least cold. 

Shipping any other way will take several days and can ruin the samples.

Be sure that all samples are frozen, shipped in a hard-sided cooler, and kept cold during 

shipment. To keep samples cold, ship samples on ice. Do not use dry ice, since it will cause the 

sample containers to crack or break. Pack the ice into two or more layers of sealable plastic 

2015 Environmental Monitoring Plan
storage bags (e.g. Ziploc) and tape the seal closed. Use approximately twice as much bagged ice 

as water samples by weight. Therefore, for every three water samples, field personnel must 

place 10 pounds of ice into the cooler. Unsealed ice will melt and leak during shipment, causing 

unnecessary concern in transit or when received at the laboratory.

Documentation

Complete a separate APHIS 2060 form for each sample collected. Only use original 2060 forms 

because separation and routing of the copies is required. Instructions for completing the APHIS 

2060 forms are on the back of each form. All appropriate sections of the form should be 

completed. Samples should be marked as “routine” unless they were collected for a complaint or 

incident investigation where they should be marked as “priority.” For each sample, submit the 

blue copy of the APHIS 2060 form to the laboratory. The blue copy is in effect the sample label 

and must be included in a sealable plastic bag with the sample. After packing the cooler with 

samples and bagged ice, place all the white copies of the 2060 forms for every sample in a single 

sealable plastic bag on top of the samples inside the cooler. The bundle of white copies provides

the laboratory personnel the information they need to properly unpack the cooler and sort the 

samples. Send the yellow copy of the form (and any maps, photos, etc.) to the CEC staff. Keep 

the pink copy of each form you submit as a record in your local office.

Supplies

The CPHST facility in Biloxi, Mississippi will continue to provide monitoring supplies. A form

for ordering supplies is located at the end of this document. They prefer that supply orders be 

faxed or emailed to them using the numbers listed on the checklist rather than leaving a voice 

message for orders. Note that certain general office supplies cannot be ordered by this checklist 

and should be obtained locally by the program.

Responsibilities

APHIS-PPQ Compliance and Environmental Coordination staff in Riverdale, Maryland will:

1. Review and interpret field and pesticide residue data from the habitat surveys and residue 

monitoring. Contact the surveyor or sample collector for clarification as soon as possible 

if any field data is incomplete or unclear. Notify the program managers immediately if 

any residue data is unexpectedly high in value.

2. Provide training, clarification, and interpretation on how to implement the Environmental 

Monitoring Plan (EMP).

3. Submit a comprehensive interpretive report to the program managers within 90 working 

days of receiving all of the field data.

APHIS-PPQ Center for Plant Health Science Technology staff in Mississippi will:

1. Prepare and ship sampling containers and equipment required for collection and 

submission of environmental monitoring samples.

2. Provide instructions on methods for collecting, preserving, and shipping samples.

2015 Environmental Monitoring Plan
3. Coordinate communication between the PPQ - Environmental Compliance staff and

AMS-NSL and APHIS-Miami to resolve sample condition and analysis issues.

4. Review and report analytical results to PPQ - Environmental Compliance.

APHIS-PPQ Field Personnel or Cooperators, will:

1. Ensure that sufficient resources from the Program are allocated for completing the 

monitoring activities described in the Environmental Monitoring Plan (EMP).

2. Follow instructions in the EMP and referenced SOPs to develop a plan for sample 

collection and documentation, including:

a. Collect the type and number of samples recommended in the EMP.

b. Complete of a separate APHIS 2060 form for each sample that is collected.

c. Provide all the information necessary to document the samples. Send all supporting 

documentation, including a copy of the appropriate APHIS 2060 forms to the CEC 

staff. 

d. Submit routine samples to the AMS-NSL in Gastonia, North Carolina for residue 

analysis and send priority or emergency samples to the CPHST-AQI laboratory in 

Miami, Florida. 

e. Notify the laboratory and the CEC staff prior to shipping any priority, spill, or 

unusual (i.e. other than water, insect, or vegetation) samples.

2015 Environmental Monitoring Plan
Environmental Monitoring Supplies Checklist

- use the blank areas to indicate the number of items to take to the field or 

how many of that item are being ordered

General Supplies Dye Cards

Monitoring plan/SOP’s Obtain from 

ECT

Oil-sensitive dye cards (one card 

per package)

Field log notebook Water-sensitive dye cards (two 

paired cards per package)

2060 monitoring forms 5' bamboo poles/stakes Obtain locally

Indelible marker Obtain locally Paper/alligator clips Obtain locally

12” x 12" resealable plastic bags Tacks/nails Obtain locally

Large or small coolers for mailing Tweezers Obtain locally

Shipping label (AMS-National 

Science Laboratory in Gastonia, NC) Nitrile gloves (box of S,M,L,XL)

Indicate size

Packing/strapping tape Vegetation/Fish/Insect Samples

Ice chest and wet or blue ice Obtain locally Pruning shears/scissors Obtain locally

Soil Samples Tweezers/forceps Obtain locally

Hand trowel Obtain locally Packing/strapping tape

10” x 14” foil envelopes 10” x 14” foil envelopes

Neat (Pure) Chemical & Formulations Water Samples

Amber glass bottle (2 ounce size) Cubitainer (gallon size)

Disposable pipette and bulb Cubitainer (liter size)

Small mailing tubes Sodium sulfate (small vials)

Protective eyewear pH paper (0-14 range)

Nitrile gloves (box of S,M,L,XL) Indicate size Acid or base (in a squeeze bottle) Obtain locally

Program: _________________________________ Requested by: ______________________________ 

Date: _____________________________________ Phone: ____________________________________ 

Address: ____________________________________________________________________________________

____________________________________________________________________________________________

To order supplies, indicate the quantity of each item needed. Fax or email a copy of this form to CPHST in 

Mississippi at 228-385-9280 or robert.d.smith@aphis.usda.gov. If fax machines are not working, leave a message 

with the CPHST monitoring supplies manager at 228-215-4729. It may be difficult to fill orders for large quantities 

of materials.

This is not an exhaustive supply list...items that are not listed here may be available through CPHST. Not all 

supplies listed above are required for all pest control programs.

2015 Environmental Monitoring Plan